The French impatriate regime: moving to France to work
Article 155 B of the French Tax Code exempts from income tax, for up to eight years, the impatriation premium of employees and executives recruited from abroad, and half of certain foreign-source income.
The firm checks the conditions for the regime, determines the exempt amount, works with the employer on the drafting of the contract and coordinates the regime with share-based pay granted before arrival.
Who qualifies for the impatriate regime?
- Conditions: no French tax residence in the previous five years, posting from abroad or direct recruitment.
- Contractual premium or election for the 30% flat-rate valuation.
- Caps on the exemption and the portion of pay linked to work performed abroad.
- 50% exemption of passive foreign-source income.
- French taxation of RSUs, options and carried interest granted before arrival.
What are the figures and thresholds for 2026?
| Item | Value | Reference |
|---|---|---|
| No prior French tax residence | Previous 5 calendar years | Art. 155 B CGI |
| Length of the exemption | Until 31 December of the 8th year | Art. 155 B CGI |
| Flat-rate valuation of the premium | 30% of net pay | Art. 155 B CGI |
| Exempt passive foreign-source income | 50% | Art. 155 B CGI |
In which cases has the question arisen?
Returning to live and work in France after several years abroad
Advising a senior executive returning to France: date of tax residence, inbound (impatriate) regime, treatment of foreign income and assets, and IFI for new residents.
Hiring a first employee in France
A foreign company hiring its first employee in France without a subsidiary: choice of employment structure, employer registration with the Urssaf, French payroll and permanent-establishment risk.
Qualifying a Group RSU Plan for France
A global RSU plan applied to France with no addendum: every delivery taxed and charged as salary. Five ancillary clauses stood in the way of qualification; a French addendum removed them, without touching the global plan.
Securing the taxation of carried interest during an international relocation
A private equity professional moving to France with carried-interest and co-investment rights in foreign funds: eligibility for the regime (articles 150-0 A and 163 quinquies C of the CGI) and coordination with mobility.
Frequently asked questions
Who qualifies for the impatriate regime?
Under article 155 B of the French Tax Code, employees and executives recruited from abroad to work in France who were not French tax resident in the five calendar years before taking up their post.
How long does the regime last?
The exemption applies until 31 December of the eighth year after taking up the post in France.
What if the contract provides for no impatriation premium?
A person recruited directly from abroad may elect for a flat-rate valuation of the premium equal to 30% of their net pay.
Answers current as at 9 October 2026
Legal texts
See also
Publications and award
2026 OCCUR Prize, Interprofessional CollaborationLa Rencontre OCCUR Paris
Press contribution · 24 June 2026Entrepreneurs: structuring your wealth alongside your business (in French)
Expert view · 6 October 2026Pharmacy owner’s remuneration: three structures, three approaches (in French)- Interview · 28 September 2026Setting up and handing over a pharmacy: why and how to plan ahead (in French)
ArticlesThe firm’s articles on the National Bar Council’s platform
Joint publication · 26 July 2026BSPCE: no contributions, but a line in the DSN payroll returnwith Arnaud Albalat (Galadrim) and Laura Sinthe (Puncto)
AbracamoveJoint publicationInternational retirement: what the country of residence changeswith Delphine Bes (Abracamove)
Discussing your situation
A first meeting identifies the questions raised by your situation and the work they call for.